Financial Grants Management Presented by: Donna Teague Grant Accounting Supervisor El Paso County Auditor s Office Small Counties Large Counties Grants Management Records Session Outline New Application Requirements Grants.gov CCR Filings and DUNS Numbers Federal (A-133 Audits) Texas Single Audit Effects of ARRA Funds Roles Planning Can the county effectively manage grants? Does the county have a reliable financial management system to handle the internal controls, such as budgeting, accounting, recordkeeping, reporting, payroll and timekeeping? Does the county have sound support system for procurement, legal, and human resources? Can the county maintain the required data to meet grant reporting requirements? Will you have sub-grantee? If so, who will monitor them? How will the county handle the cash flow? Will the county need to get an advance, request reimbursements monthly or quarterly? Can the county handle matching funds requirements? Cash and/ or in-kind? 1
Roles-continued Grant seeking -Application Process Does the county have the ability to research and seek out grants? What is the process to apply for grants for the county? Does the grant have matching requirements? Does the county have the proper departments involved in the process? Program department, budget, financial, human resources and legal? Can the county do what they propose in the application? Legally and Ethically? Roles-continued Budget and Compliance Can the county ensure that the expenditures are in compliance with the award, budget, federal, state and local law? Who is responsible for reporting? Program/ performance and financial? Who handles the disputes? Roles-continued Evaluation, Audit and Closeout Who is responsible for assuring that grants funds are being used to meet expected outcomes? Both internal and external? Who determines whether these grants needs to be audited or just monitored? Who closes all the obligations in the grant period? If funds are received in advance, who returns unexpended funds? Who handles return of interest, if needed? Who submits or prepares final reports? Program/ performance and financial? Who is responsible for record retention? 2
Small Counties-Most functions handled by the department who will use the funds or perform the duties. Several items that need to be remembered: Is the county able to achieve the grant purposes? Will the grant require a county to have an audit done although it is not required by the Single Audit Act OMB-133 or the State Single Audit Act? Will there be clear separation of duties? Large Counties- Usually have enough staff and departments to assure the separation of duties. They usually have larger accounting, human resources and legal departments. Although that can work against them if there is a lack of communication and cooperation between the departments. They need to make sure that they are working together: recipient, human resources and accounting. Usually larger counties will be required to have outside single audits performed. Grants Management Records Grant records to keep on hand to help with future reporting, audits or monitor visits: 1. The application. 2. The Award-including any special conditions. 3. A list of contact people, including federal, state and local contacts. 4. The budget as awarded and any subsequent amendments. 3
Grants Management Records 5. Any guidelines that the agency provides, whether program and/or financial! 6. Determine the funding sources; federal, state, local and/or foundation. 7. If the grant is federal funds, look up CDFA (Catalog of Federal Domestic Assistance) number and see if there are any special requirements. 8. Keep a copy of all certifications made: such as salary, suspension and debarment certifications, equal opportunity and drug free work place. 9. Inventory records. New Application Requirements Most Federal Agencies require that you register with the web site www.grants.gov. Public Law 106-107 Federal Financial Assistance Management Act of 1999. In order to apply for grants you must register with the CCR (Central Contractor Registration). You will need to have a DUNS (Data Universal Numbering System) Number which is assigned by Dun & Bradstreet, Inc. Federal OMB Circular A-133- Audits of States, Local Governments, and Non-Profits Organizations Placed in to law July 5, 1996. OMB Circular A-128 Audits of States and Local Government issued in 1985, was rescinded as a result of the consolidation of audit requirements under Circular A-133. A change in 1996 was that the audit requirement limit was raised from $25,000 to $300,000. In 2005 the audit requirement limit was increased to $500,000. Circular A-133 Compliance Supplement became effective on June 30, 1996. This changed the audit approach from Risk- Based Approach to Determining Major Programs. 4
What are Federal Awards? Federal Awards are federal financial assistance and federal cost-reimbursement contracts that non-federal entities receive directly from federal awarding agencies or indirectly from pass-through entities. For example: grants, loans, loan guarantees, cooperative agreements and donated surplus property. The Schedule of Expenditures of Federal Awards The Schedule of Expenditures of Federal Awards is a report that is sent to the Federal Clearinghouse along with the data collection form. It includes: List of Federal awards by Federal agency. The related CFDA (Catalog of Federal Domestic Assistance) number. The contract or grant number. The amount of expenditure. Note: This list should also include funds received as a subrecipient. The Schedule should also include any audit findings (prior and current) and corrective action plans. Report submission should be done within the 30 days after receipt of the auditor s report or 9 months after the end of the audit period. The schedule of Federal Expenditures should be submitted along with the Data Collection Form through the Federal Audit Clearinghouse. This is now done online at: http://harvester.census.gov/sac/. 5
Independent auditors - Are required to follow the GAGAS (Yellow Book). Must determine whether the Financial Statements are presented fairly in conformity with GAAP and the Schedule of Federal Expenditures is presented fairly in relation to the Financial Statements. Auditors are to determine Type A Awards(Low risk) or Type B Awards (High Risk or Major Programs). The determination of Type of Awards is a calculation set by the OMB A-133 and the amount of expenditures in the fiscal year, except if the agency states that their awards will always be considered Major, such as ARRA (American Recovery and Reinvestment Act). They use the CFDA number located in the OMB Circular A-133 Compliance Supplement for allowable activities, costs, matching and other activities. Texas Single Audit State of Texas Single Audit Circular "State award" means state financial assistance and state cost-reimbursement contracts that local governments receive directly from state awarding agencies or indirectly from pass-through entities. State awards do not include federal awards as defined in OMB Circular A-133 (whether the federal awards are passed through a state agency or received directly from a federal agency). Texas Single Audit Entities that expend $500,000 or more in a year in state awards shall have a single or program-specific audit conducted for that year in accordance with the provisions of this audit circular. Entities can choose to do two Schedules of Expenditures, one federal and one state or combine both in one report. 6
ARRA Funds The Federal government has added more reporting requirements usually monthly. The programmatic reporting has changed and are now requiring metrics and evaluation. They have a Buy American Provision. Also include Wage Rate requirements referred to as Davis-Bacon. Note: Prime recipients are responsible for subrecipients and contractors. All guidelines and provisions flow to sub-recipients and contractors. 7
ARRA Funds ARRA funds are always considered Major Programs. ARRA funds (American Recovery and Reinvestment Act) must meet certain basic ideals: Accountability --Public benefits of funds are reported clearly, accurately and in a timely manner. Funds must be tracked with CFDA numbers and accounted for separately whether recipient or sub-recipient. Transparency --Recipients and usage of all funds must be transparent to the public. Must be reported in the Schedule of Expenditures of Federal Awards even if the CFDA number is the same as other funds received. The ARRA funds are to be noted separately. Recipients must require their sub-recipients to properly report ARRA funds. Congressional Sensitivity --Funds are used for authorized purposes. ARRA Funds Potential penalties of noncompliance: Findings for recovery. Debarment or suspension. Termination of Federal Funding. Subjection to Fraud Investigation. Any and all may apply. Web Sites www.recovery.gov American Recovery and Reinvestment Act www.cfda.gov Catalog of Federal Domestic Assistance www.whitehouse.gov Office of Management and Budget www.grants.gov Grants.gov www.bpn.gov/ccr Central Contractor Registration www.dnb.com Dun and Bradstreet, Inc. http://harvester.census.gov/sac/ Federal Audit Clearinghouse www.gao.gov GAO US Government Accountability Office http://governor.state.tx.us/grants Office of the Governor grants 8